On March 8, BPI submitted a response to the California Attorney General’s request for preliminary rulemaking comments on implementing the California Consumer Privacy Act (“CCPA”). The letter recommends that any rule account for the robust privacy frameworks financial institutions already have in place and focus on protecting information provided to a business by a customer in their personal capacity, consistent with the CCPA’s legislative intent. The letter also calls for a transitional implementation period, with CCPA compliance requirements and enforcement activity beginning no sooner than twelve months after regulatory standards are finalized.